United States v. Tan

November 12, 2010

UNITED STATES OF AMERICA, PLAINTIFF,v.TEVIN TAN, DEFENDANT.

STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE

IT IS HEREBY STIPULATED by and between Plaintiff United States of America and Attorney Danny D. Brace, Jr., Counsel for Defendant Tevin Tan, that the status conference scheduled for November 15, 2010, be continued to December 13, 2010. The request to continue the status conference is made on the ground that defense counsel needs additional time to prepare. Danny Brace recently replaced Mr. Tan's original counsel in this case. The defense needs additional time to review a previously-provided plea agreement and discuss potential motions and defenses with Mr. Tan.

Both parties agree that an exclusion of time is appropriate under 18 U.S.C. § 3161(h)(7)(B)(iv); Local Code T4 (reasonable time to prepare). Danny Brace agrees to this request and has authorized Assistant United States Attorney Todd D. Leras to sign this stipulation on his behalf.

1. The status conference set for November 15, 2010, is continued to December 13, 2010, at 8:30 a.m.

2. Based on the stipulations and representations of the parties, the Court finds that the ends of justice outweigh the best interest of the public and Defendant in a speedy trial. Accordingly, time under the Speedy Trial Act shall be excluded under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4 (reasonable time to prepare) up to and including December 13, 2010.

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